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in and experience with horses, hired others with expertise for
buying, training, and showing her animals. She knew that in
order to be successful, she would have to acquire and/or breed
championship quality stock.
Her first acquisition of mares and attempts at quality
offspring did not work out due to circumstances beyond
petitioner’s control. She continued to make new acquisitions of
breeding stock and had others train and show her horses.
Petitioner, however, also purchased horses that did not comport
with her goal of producing a champion stallion during the period
under consideration. In fact, at the time of trial she had about
10 horses, only a few of which had the potential to be or to
produce a champion stallion. Petitioner did not attempt to cut
her overhead or losses by either ridding herself of unproductive
horses or limiting her acquisitions to horses that would assist
in a profit-oriented goal.
Petitioner testified that her overall approach was directed
toward the achievement of an income stream; however, she
experienced practically no income during the 9-year period from
1989 through 1998 and did little to cut her expenses/losses.
Even though petitioner believed that one of her young stallions
had the potential to recoup more than the $131,000 in incurred
expenses/losses, no independent or reliable evidence was supplied
to show that her stallion's potential or any stallion's potential
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